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We are concerned STRs are being used as a scapegoat for the much larger challenges faced by Santa Ana and California as a whole when it comes to developing affordable housing. At a minimum, the City should study the relationship between STRs and long-term housing availability in Santa Ana before taking any action to restrict STRs. There Is No Basis for the Adoption of an Urgency Ordinance The City seeks to make the proposed STR prohibition effective immediately by using the Urgency Ordinance, pursuant to Sections 415 and 417 of the City Charter. (Urgency Ordinance at 2.) Section 415 of the City Charter provides that the City Council can adopt an ordinance that it declares to be "necessary as an emergency measure for preserving the public peace, health, or safety, and containing a statement of the reasons for its urgency" by a two-thirds vote of the members of City Council. (Santa Ana Mun. Code, § 415.) Here, the City has not, and cannot, make the required findings to pass the Urgency Ordinance because STRs do not represent a "current and immediate threat to the public health, safety, or welfare." As discussed above, there is no evidence in the record that STRs are a nuisance. Recent guidance from the California Attorney General on urgency ordinances notes that "the immediacy requirement is satisfied in `situations where local agencies were faced with immediate threats of development[]' and that an urgency ordinance's findings must document the nature of the threat to the public health safety or welfare." (July 17, 2023, Letter from California Office of the Attorney General to all Cities and Counties in California, pp. 2-3; see also San Francisco Fire Fighters Local 798 a City and County of San Francisco, 38 CalAth 653, 668 (Cal. 2006) (noting that a court "will not investigate the truth of the facts declared by the city council," however, it may review if "a city council's determination [that] the declaration of facts is sufficient to constitute an urgency" and "[t]he mere declaration of the council that the ordinance is passed for the immediate preservation of public health," absent findings of fact the reasonably support that finding, "is neither conclusive nor sufficient.").) The Urgency Ordinance fails in this regard. There is no "immediate threat of development" because STRs are currently legally operating in the City. Further, the declaration in the Urgency Ordinance is completely devoid of any factual support that existing STRs are harming public health, safety, or welfare, and thus fails as a matter of law. STRs Provide Countless Benefits to the City, its Residents, and its Visitors Staff appears intent on using STRs as a scapegoat for the challenges the City faces when it comes to housing availability and other issues. The complete lack of evidence in the staff report supporting this ban makes that clear. The City Council should reject the one-sided proposal advanced by Staff and give weight to the substantial benefits provided by STRs prior to taking action. As hosts, we open our homes to guests and allow them to experience Santa Ana in unique ways. Santa Ana becomes their home when they stay at our houses, even if it is for a short period. We expand opportunities to learn about and experience our community and the rest of Southern California. Importantly: